Why the Scottish Home Report Doesn’t Work for England and Wales
Every so often, I hear someone say, “Why can’t we just adopt the Scottish Home Report in England and Wales? Wouldn’t that solve everything?”
It’s a fair question. On the surface, the Scottish system looks neat and consumer-friendly: one report, paid for by the seller, is made available at the point of marketing. Buyers get upfront property information, and everyone knows where they stand. Compared to the patchwork of surveys, searches, and conveyancing hurdles elsewhere in the UK, it may seem like an easy fix.
But in reality? It’s not that simple. Here’s why.
What the Scottish Home Report Actually Does
Since 2008, every home put on the market in Scotland (with some exceptions) needs a Home Report. This includes:
- Single Survey: a property condition survey prepared by a chartered surveyor.
- Energy Report: the EPC.
- Property Questionnaire: completed by the seller with details like planning permissions, alterations, council tax, and utilities.
The idea is that the buyer sees this upfront before making an offer. Sellers pay for it, and surveyors are instructed directly by them.
The Appeal - and the Misunderstanding
To buyers in England and Wales, where the process is often stressful and opaque, the Scottish model sounds like a dream:
- Clarity upfront – no nasty surprises later.
- Fairness – every buyer sees the same survey.
- Efficiency – reducing fall-throughs.
But this assumes two things that don’t quite line up with how the market operates elsewhere:
- That one survey suits every buyer’s needs.
- That the legal, lending, and offer processes are the same (they’re not).
Why It Doesn’t Translate
Different Legal Systems
Scotland’s property law is fundamentally different. The conveyancing process means offers are binding much earlier. In England and Wales, we don’t have that legal framework – so even with a Home Report, buyers could still pull out late in the process.
The Offers Over System
In Scotland, most properties are marketed at “offers over” the advertised price. Buyers submit sealed bids, and the seller accepts the best one. The Scottish Home Report underpins this process: all bidders see the same survey, so they can make an informed offer with confidence.
However, Offers Over is essentially a pricing strategy – a hook, typically 7–10% under the expected selling price – designed to generate interest and viewings. It still takes traditional estate agency skill to convert that interest into a completed sale.
In England and Wales, homes are usually marketed with a guide price or asking price, and negotiation is more open-ended. Multiple buyers might each want their own advice about value and property condition before deciding how much to offer. A single seller-commissioned survey doesn’t provide that individual guidance.
Lender Requirements
Many mortgage lenders in England and Wales still want their own valuation, not just a shared survey. But things are changing. Increasingly, lenders use desktop and automated valuations (sometimes for as much as half their lending), combining internal risk models with AI rather than relying on qualified surveyors.
Scotland works differently: lenders typically rely on the Single Survey. But because surveyors must be on lender panels to produce them, they are restricted from carrying out other independent work due to conflicts of interest. The result? Far fewer buyers commission more detailed or tailored surveys. In practice, Scottish buyers may actually get less property advice than their English and Welsh counterparts.
Until lender policy shifts, a single seller-commissioned report won’t replace the need for additional checks in England and Wales. And if we move towards a Scottish-style model, the conflicts of interest around panel work could reduce the choice and independence of advice here too.
Risk and Liability
Surveyors in Scotland prepare reports knowing they may be relied upon by multiple buyers. In England and Wales, liability is normally to the client who instructed the survey. Extending that liability to every potential buyer would increase professional risk, require new insurance structures, and likely drive up costs.
It’s also important to note: Scottish reports are condition information, not advice. They are not comparable to an RICS Level 2 or Level 3 survey. If England and Wales adopted the same approach, we would need to ask ourselves: Is it right for surveyors to support a model where consumers receive less advice than they do today?
Market Behaviour
In Scotland, buyers are used to paying for their due diligence upfront, and sellers accept that they must invest before marketing. In England and Wales, the culture is different: sellers want the cheapest route to market, and buyers often shop around for advice that fits their needs.
A one-size-fits-all report may not provide the tailored guidance many buyers need. But the Material Information requirements being enforced under trading standards do give us an opportunity to “nudge” the public in the right direction – providing clearer upfront information without falling into the trap of oversimplified, generic reporting.
Lessons for the Home Survey Standard
The current Home Survey Standard (HSS) consultation doesn’t directly address these bigger questions. Its focus is on scope, clarity, and consistency – important issues, but arguably too narrow.
The now-defunct Property Surveyors Sub-Group (PSSG), which fed into the Home Buying and Selling Council, offered a broader way forward: a risk-based triage model. Instead of mandating one type of report for all, the idea was to:
- Identify which properties carry obvious risks and cause delays (e.g. spray foam insulation, off-mains drainage, unregulated extensions).
- Commission proportionate checks or certificates upfront.
- Provide consumers with clear “if this, then that” guidance so they know what action to take.
This approach builds on professional judgment, digital data, and consumer behaviour research. It’s practical, risk-led, and consumer-focused. Yet the HSS does not reference this or set the scene for surveyors to offer different types of reports or advice at all. When it comes to surveyors’ advice on consumer home purchases, RICS feels very prescriptive - but unfortunately, life is just not like that.
It feels like a missed opportunity for RICS to engage with wider reform. By not testing or considering models like triage, the HSS risks being an inward-looking exercise – one that tinkers with wording and control rather than tackling the real consumer frustrations and systemic inefficiencies.
But Why Can’t We Have Both?
Imagine a system where:
- Baseline, standardised condition information is available to everyone upfront.
- Surveyor advice builds on that baseline, personalised to the client’s needs, concerns, and future plans.
That way, consumers benefit from both clarity and confidence, and surveyors maintain their professional role as trusted advisers.
The Scottish Home Report works in Scotland because the legal system, the offer process, and lender practices all support it. But it is not a direct solution for England and Wales.
What we need is something inspired by its principles – clarity, certainty, and upfront information – but designed for our market. A triage approach, layered reporting, and better use of material information requirements could deliver a system that works for everyone, without reducing the role of the surveyor to a box-ticker.
RICS had the chance to explore this in the HSS. By not doing so, it risks missing the bigger prize: a system that delivers real reform, for surveyors, for the wider industry, and most importantly, for consumers.
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